Introduction

Are Illegal Robocallers Using Your Platform to Invade the US Telephone Network?

The information here may be useful as you work to prevent this.

US-based providers are our best defense against illegal robocallers. Industry members along with regulators and enforcers are working together to stop these calls at their source.

As a telecommunications provider, you must balance your interest in making money completing calls for your customers, against your responsibility to protect American consumers from illegal and problematic calls. If your traffic generates complaints, you may have difficulty getting downstream providers to accept it. You’ll also have to spend resources investigating those complaints and responding to potentially onerous enforcement inquiries.

The sections here can help guide you in contributing to industry efforts to minimize the robocall scourge.

One definition of “robocall” would be any call other than one dialed conventionally from one person to another. Robocalls use computerized dialing, and/or deliver a message using a prerecorded or automated voice. What Calls Are Illegal shows SOME of the extensive, sweeping regulations that are applicable to such calls. Well-written provider contracts prohibit illegal calls and specify that customers lose privileges and protections when they send illegal traffic. Many providers have provisions that extend beyond just illegal calls, to those that generate complaints or are otherwise problematic. Providers are under no legal obligation to carry such traffic and in fact most stakeholders would argue that all providers must work diligently to refuse it.

Best Practices When On-boarding New Customers explains how providers can vet new customers before giving them access to volume calling services or allowing them to supply their own Caller-ID values. US-based customers can be validated via state and federal databases and reference checks. Diligent providers obtain detailed business descriptions from foreign customer prospects, constraint their traffic commensurately, and monitor for ongoing compliance.

When Traceback Reveals Illegal Calling shows the steps a provider takes when problematic traffic comes to their attention via traceback, enforcement action, inquiry from a downstream provider or some other indication of trouble. Most important is that the provider act swiftly to address the issue. Best is to immediately (same day) suspend the traffic while the issue is investigated and only re-enable that call source if and when the calls are brought into full compliance. Allowing illegal traffic to continue while corrective action is taken will further damage the provider’s reputation. Since spoofing is a rampant practice among illegal callers, blocking a specific calling number is not sufficient — the party sending the traffic must be completely disabled.

In many cases, calls are completed through a chain of providers as a call moves hop-by-hop towards its destination. Working With Upstreams gives best practices to address and avoid problematic traffic from another provider “upstream.” Many providers blend bad traffic with good. That approach puts ALL traffic at risk, because providers need to be vigilant regarding any bad calls. The best place to stop bad traffic is at the point of origination; providers need to push their upstreams to take responsibility for traffic they originate.

Next Step: What Calls Are Illegal?